Legal drafting

        IN THE COURT OF HON’BLE CIVIL JUDGE, _________   V                          Versus                    R SUIT FOR PERMANENT INJUNCTION WRITTEN STATEMENT  ON BEHALF OF DEFENDANT RESPECTFULLY SHOWETH:- PRELIMINARY OBJECTIONS:- 1-             That the instant suit filed by the plaintiff is not maintainable in the eyes of law against the answering defendant. 2-             That the plaintiff has no cause of action for filing the present suit against the answering defendant, if any, mentioned in plaint then is false & made-up. 3-             That the plaintiff has no locus-standie for filing the suit as the plaintiff had entered into an agreement to sell in respect of suit property with the answering defendant on 29-11-2011 for a total sale consideration of Rs. 1,80,000/- and the plaintiff has executed an agreement to sell-cum-receipt in favour of the answering defendant. The plaintiff had received an amount of Rs. 1,00,000/- in cash from the answering defendant

REPOSSESSION AGENCY AGREEMENT This Agreement entered into on this _______ day of _______ 2014 between   M/s INDUSIND BANK LIMITED, a company incorporated under the Companies Act, 1956 and licensed to conduct Banking operations under the Banking   Regulation Act, 1949, having its registered office at No. 2401, General Thimmayya Road. ( East Street), Cantonment, Pune- 411011 and having its Administrative office- Retail Banking Division at 115,116, G N CHETTY ROAD, T NAGAR CHENNAI-600027 represented by its Regional Manager Mr. _____________________________, hereinafter called as the “ IBL ” , AND A firm/ individual carrying on the business of rendering service of locating and repossessing the asset on the instruction of Financier/ (s) and represented herein by M/s. ________________, hereinafter referred to as the “ AGENT ” (The term IBL and AGENT include their/his heirs, successors, administrators, assigns and legal representative) Whereas IBL is carrying on the business of F

             IN THE HON’BLE COURT OF CIVIL JUDGE (SENIOR DIVISION), ____ 1-   Bir Singh, 2- Tek Chand, 3- Saroop Singh @ Samay Singh sons of Sh. Kishan Lal son of Ganga Sahai, resident of village _______, ______, Distt. _______, 4- Smt. Poonam wife of Sh. Kundan Singh son of Sh. Kishan Lal, herself as well as legal heir of Sudhir Attri son of Sh. Kundan Singh son of Sh. Kishan Lal, 5- Ranbir @ Randhir son of Sh. Kundan Singh son of Sh. Kishan Lal,   resident of Sector-8, Faridabad.                                                                                                ....... Plaintiffs. Versus. Deepak son of Sh. Naresh Kumar son of Sh. Madhoram, resident of________, Distt. _______ .                                                                 ………Defendant. Suit for Declaration and permanent injunction. Respected Sir,                          The plaintiffs humbly submit as under:- 1.    That the plaintiffs being owner in possession   of agricultural land